IR 05000277/1985033

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-277/85-33 & 50-278/84-27

ML20205A640
Person / Time
Site:	Peach Bottom
Issue date:	04/11/1985
From:	Harpster T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
NUDOCS 8504250566
Download: ML20205A640 (2)

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APR 111985 Docket Nos. 50-277/50-278 License Nos. DPR-44/DPR-56 Philadelphia Electric Company ATTN: Mr. S. L. Daltroff Vice President Electric Production 2301 Market Street Philadelphia, Pennsylvania 19101 Gentlemen:

Subject: Combined Inspection Report Nos. 50-277/84-33 and 50-278/84-27 This refers to your letter dated March 8, 1985, in response to our letter dated February 6,1985.

Thank you for-informing us of the corrective and preventive actions documented in your letter. These actions will be examined during a future inspection of-your 1.icensed program.

Your cooperation with us is appreciated.

Sincerely, Original Signed By:

Terry Harpster, Chief Emergency Preparedness Section Division of Radiation Safety and Safeguards cc:

/R. S. Fleischmann, Station Superintudent dohn S. Kemper, Vice President, Engineering and Research

-- Troy B. Conner, Jr. , Esquire-Eugene J. Bradley, Esquire, Assistant General Counsel

--Raymond L. Hovis, Esquire M homas Magette, Power Plant Siting, Nuclear Evaluations Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

W RC Resident Inspector Commonwealth of Pennsylvania hok G

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OFFICIAL RECORD COPY RL PB 84-33/84-27 - 0001.0.0 \

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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 SHIELDS L. D ALTROFF (215) 841 5001 wCs passiocer SLSCTalC PnODUCf m March 8, 1985 Docket Nos. 50-277 50-278 Mr. Thomas T. Martin, Director Division of Engineering and Technical Programs U.S. Nuclear Regulatory Commission i Region I 631 Park Avenue King of Prussia, PA 19406

Dear Mr. Martin:

Your letter of February 6, 1985, forwarded combined Inspection Report 50-277/84-33 and 50-276/84-27. Appendix A of your report addresses one iten.which does not appear to be in full compliance with_ Nuclear Ecgulatory Commission requirements.

This item is restated below along with our response:

-icchnical Specification 6.8 requires implementing the recommendations of ANSI H18.7. Section 5.3 of ANSI NIE.7 (1972) requires procedures for implementing the emergency plan actions. Administrative Procedure A-21, novision 5, April 20, 1981, Generation of Emersency Plan Procedures, requires proccdures to include necessary action levels.

Contrary to the above, from about October 12, 1984, to about 5:00 p.m. October 16, 1984, Emergency Plan Implementing Procedure EP-101, Ecvision 9, dated October 12, 1984, Classification of Emergencies, was inadequate

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in that the procedure specified emergency action levels for the reactor building ventilation and main stack radiation monitors that were in three instances above full scale for the instruments; and the emergency action levels for the ventilation stack high range radiation monitor were apparently incorrect, as the value specified for an Alert was below the normal background

< reading. Also, procedure EP-101, ncvision 8, effective

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[ from January 10 to October 12, 1984, contained one instance where a specified action level for the reactor

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lir . Thomas Pasc 2 building ventilation stack was above full scale for the instrument.

This is a severity Level IV Violation (Supplement I).

Responsc This violation was cauced by procedural deficiencies in EP-101, " Classification of Emergencies."

EP-101, Revision 9, specified the following Emergency Action Levels (EAL's) for the associated radiation monitoring instruments:

Action Level Instrument EAL (cpm)

Site Emerg. Rx Bldg Vent. (Norm. Range) 2.5P6 or Rx Bldg Vent. (Hi Range) 1.5PS

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General Emerg. Rx Blds Vent. (Ucrm. Range) 2.5P7 or Rx Bldg Vent. (Hi Range) 1.5P9 The radiation monitoring instruments are capable of indicating the EAL's specified above. The process radiation signals for the normal range instruments are digitally displayed and an analog signal is then generated to drive the associated recorder. Operation of a range selector switch is required to change the reccrder range, but the switch operation has no ef fect on the digital display. The digital display will continue to indicate increasing radiation levels regardless of a full scale indication on the recorder.

Procedure EP-101 was inadequate because use of the digital indication was not specifically stated in the procedure, and because a range cwitch change to record the indication was not procedurally addrecsed.

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The Alert EAL specified in Revision 9 of EP-101 for a reactor building ventilation release was 1.5P7 counts per minute (cpm) on the High Range monitor. The bottom i of scale of this instrument is 1.0P7 cpm, but because this instrument would be downscale during normal conditions, a light source is used to create a live zero. The device causes an inctrument reading on scale at approximately 1P8 cpm. Because of an oversight, the artifical elevated "zero" was not considered when the Alert EAL was revised and incorporated into EP-101. The normal range instrument EAL that procedurally accompanied the High Range instrument EAL in Revision 9 of EP-101 would have prompted operators to enter an Alert. In addition, a calculated value which was

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Mr . Thomas T. Mar tin Page 3 outside the normal instrument range was incorporated into EP-101, Revision 8 and 9 for the Main Stack General EAL. However, the procedure also included an EAL for the High Range monitor which was within the instrument

. range and would have procpted escalation into a General Emergency.

When informed of the procedure problem by the NRC inspector, a temporary procedure change was immediately initiated to correct the inadequacies. On November G, 1984, Procedure EP-101 was revised .(Revision 10) to reduce the Main Stack and Reactor Building ventilation General and Site EAL's to values which can be observed on the normal range recorders without operatins the range celector switches. As a result, all references to the high range monitors, except for the Main Stack General EAL, were no longer required and were deleted from the procedure.

These corrective actions resolved the deficiencies identified by your inspection. We are continuing our review of the EAL values to determine their practicality and we expect future revision with the establishment of new EAL's.

Should you require additional information, please do not hesitate to contact us.

Very truly yours,

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cc: T. P. Johnson, Site Inspector m